-9- satisfied the verification requirement of section 6330(c)(1), Yacksyzn v. Commissioner, T.C. Memo. 2002-99; cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121 (2001). Petitioners have not demonstrated in this proceeding any irregularity in the assessment procedure that would raise a question about the validity of the assessment or the information contained in Forms 4340. See Mann v. Commissioner, supra. Second, petitioners argue that the Appeals officer made his determination without affording them a hearing. Respondent replies that petitioners “were given ample opportunity for a face-to-face hearing.” Because petitioners allege that a hearing under section 6330 was not properly held, the question arises whether this Court should remand the case to Appeals to hold the hearing. Such a question is the subject of Lunsford v. Commissioner, 117 T.C. 183 (2001). There, the Court declined to remand the case to Appeals to hold a hearing at which to consider the taxpayer’s arguments. The Court stated that the Court believed it neither “necessary or productive” to do so because “the only arguments that * * * [the taxpayers] presented to this Court were based on legal propositions which we have previously rejected.” Id. at 189. The same is true here. Apart from their contention about being denied a hearing, petitioners’ only argument in this proceeding, as gleaned from the allegations of error that theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011